Privacy

Table of Contents

1 General

1.1 The following provisions govern the handling of your personal data by Locumi Labs GmbH, Zweibrückenstr. 2, 80331 München, Germany, (in the following “Locumi”) with regard to nello tello, nello one (both of them together in the following “Products”), nello platform (“Platform”), the nello mobile app (“App”) and the nello website available at www.nello.io.

1.2 You can access this information at any time within the App, retrieve it from the website at nello.io/privacy

2 Data controller

Locumi is the data controller with regard to all data processed as described in the following.

3 Products, Platform, App and Website

The following provisions of this section 3 do apply to the use of the Products, the Platform and the App.

3.1 Automated data collection

3.1.1 When the Platform is accessed via the App or via another device, for technical reasons, the following data will automatically be transmitted to Locumi: IP address, date and time of access, endpoint that was accessed, status/result of the endpoint action, the session id of the user, secure cookie and geolocation.

3.1.2 When the Products or the App are used, for technical reasons, the following data will automatically be transmitted to Locumi: type of intercom, intercom bell signal, intercom buzzer signal, dialer intercom number, every entrance attempt (successful and unsuccessful), the code that was said, who tried to enter and the recording of the call.

3.1.3 The foregoing data will be used to technically enable you to use the Products, the Platform and the App. Additionally, the data may be evaluated for statistical purposes and to improve the service offered in a pseudonymous form. You may object to such use of your data. See section 8.2 for further details.

3.2 Data entered by the user

3.2.1 1.1.1 Before being able to use the Platform and the App, you have to create a user account. For this purpose, you must enter first name, last name, e-mail address, address, password and door opening codes if applicable. These data are required in order to create and administer the user account for you.

3.3 Cookies

3.3.1 We use cookies on the Platform, the App and Website to give you the best user experience. Cookies are sets of data which are stored by your web browser and which contain data. If your consent is necessary in this respect, cookies will only be used if you have granted the required consent.

3.3.2 You also may deactivate the use of cookies and remove existing cookies in your web browser. For further information, please refer to your browser's help function.

3.3.3 In case you prevent the storage of cookies by setting your browser software accordingly, you may possibly not be able to fully use all features on the App, Website and Platform.

3.4 Third Party Providers

By using the Products in combination with Amazon Echo recordings of your voice and other data will be transferred and processed to Amazon.com, Inc., P.O. Box 81226, Seattle, WA 98108-1226. For further information on the processing of your data by Amazon.com, Inc., please go to https://www.amazon.com/gp/help/customer/display.html?nodeId=468496. We do that to enable you to open the door through your Amazon Echo product.

If you are using the Products in combination with smart locks of Nuki Home Solutions GmbH, Münzgrabenstraße 92/4, 8010 Graz, Austria, or Lockitron Mountain View, Californa, data will be transferred and processed by these entities. For further information on the processing of your data by Nuki, please refer to https://nuki.io/en/service/privacy/. For further information on the processing of your data by Lockitron, please refer to https://lockitron.com/privacy. We do that to enable you to open the smart lock at your apartment door through the App.

We use celery to process pre-orders. The service by Airbite, Inc., San Francisco, US will receive the following data from you: name, address, telephone number, e-mail address, phone number, physical contact information, credit card information, shipping, billing and other information you provide to purchase and item, other information from your interaction with the website, service and content, including device id, computer and connection information, statistics on page views, traffic to and from the sites, ip address and standard web log information.

If you are using nello tello, the following data will be transferred to Tropo LLC, 170 West Tasman Drive, San Jose, CA 95134: Recording of voice. For further information on the processing of your data by Tropo LLC, please go to https://www.tropo.com/terms-policies/privacy-policy/. We do that to enable keyless access for dialer systems and automated voice recognition of access codes.

If you are using the survey tool on our website data the data you entered will be transferred to Qualaroo, Inc, San Mateo, US. In addition to that it will be made available to us. For further information on the processing of your data by Qualaroo, Inc, please go to https://qualaroo.com/privacy-policy/. We offer that service to increase customer satisfaction and customer insights.

If you are using the survey tool on our website data the data you entered will be transferred to Qualaroo, Inc, San Mateo, US. In addition to that it will be made available to us. For further information on the processing of your data by Qualaroo, Inc, please go to https://qualaroo.com/privacy-policy/. We offer that service to increase customer satisfaction and customer insights.

3.5 Website and App Tracking Tools

3.5.1 We use the following website tracking and analysis technologies which are provided by third party providers. All of these technologies use cookies.

3.5.2 1.1.1 On behalf of Locumi, the providers listed below do collect information in order to analyse your usage of the Platform and the App in an anonymized way, to compile reports on your activities on the Platform and within the App, and to provide further services to Locumi relating to the usage of the Website, platform and the App. The IP address transferred to us by your browser within the framework of the following technologies will not be combined by the providers with other data.

3.5.3 The data collected by the providers will be collected in anonymized user profiles.

3.5.4 Google Analytics and Google Tag Manager

3.5.4.1 The Website and the App use Google Analytics, Firebase Analytics and the Google Tag Manager, which are analysis services provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The information generated by the cookie regarding your use of the Website and the App is usually transferred to a Google server in the USA, and is stored there.

3.5.4.2 As the IP anonymization function is activated on the Website and the App, your IP address will be shortened by Google within Member States of the European Union or other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will Google transfer the full IP address to a Google server in the USA, and will shorten it there.

3.5.4.3 You can prevent collection by Google of the data generated by the cookie and relating to your use of the Website and the App (including your IP address), as well as processing of these data by Google, by downloading and installing the browser plug-in provided at the following link: https://tools.google.com/dlpage/gaoptout. As an alternative to the browser plug-in or within browsers on mobile devices, you can click this link in order to opt-out from being tracked by Google Analytics and the Google Tag Manager within the Platform in the future (the opt-out applies only for the browser in which you set it and within this domain). An opt-out cookie will be stored on your device, which means that you will have to click this link again if you delete your cookies.

3.5.5 This app uses Apple App Analytics which is an analysis service provided by Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, US. For more information please refer to https://www.apple.com/privacy/privacy-policy/. We use this service to constantly improve the usability of our App.

3.5.6 The Website uses crazyegg, an analysis service by Crazy Egg, Inc., La Mirada, CA, US. The following data will be transferred: browser information, operating system information, mobile device information, ip address, page accessed geographic location, time of visit, referring site, application or service. For more information please refer to https://www.crazyegg.com/privacy. We use this service to constantly improve the usability of our Website.

3.6 Social Plug-ins

3.6.1 Our website may contain links to other websites or features from third party providers. This Privacy Policy covers the privacy practices by Locumi, and does not cover the privacy practices of third party websites or providers. Locumi is not responsible for the privacy policies or practices of third parties. With regard to any data processing by such third parties, we refer to their respective privacy policy. The following social plug-ins are available on our website:

3.6.2 Facebook

3.6.2.1 We use Facebook Like/Share button social plug-ins (provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland) to enable you to easily “Like”/“Share” content found on our website, and thereby share this content with your Facebook Friends. No data is transmitted to Facebook by simply visiting our websites. Data is only transmitted when you have enabled the plug-in by clicking on the corresponding link.

3.6.2.2 Whenever you view a page of our website containing such plug-in being enabled, your browser establishes a direct connection to the servers operated by Facebook. As a result, the content of the social plug-in is transferred by Facebook directly to your browser and embedded in the website being shown. If you visit our website whilst signed in to your Facebook user account, information concerning your visit will be transferred to Facebook and Facebook can assign your visit to our website to your user account. Please note that a data transfer is triggered already when you visit our website with social plug-ins being enabled, irrespective whether you interact with the plug-in. Information arising from interaction with the Facebook plug-ins (such as by clicking the Facebook “Like”/“Share” button or by leaving a comment) will be directly transferred to and stored by Facebook. To prevent this you must log out of your Facebook account before visiting our website. Please refer to Facebook’s privacy policy https://www.facebook.com/policy.php for more information on the purpose and scope of data collection and data analysis undertaken by Facebook as well as your options to modify settings and how to protect your privacy.

3.6.3 FACEBOOK CONVERSION TRACKING

Moreover the website uses Facebook’s "Visitors Action pixels" to support online marketing measures. With its help we can track the actions of users after they have seen or clicked on a Facebook advertisement. This enables us to detect the effectiveness of Facebook advertisements for statistical and market research purposes. The data is used in accordance with Facebook's Data Use Policy (https://www.facebook.com/about/privacy).

3.6.4 FACEBOOK REMARKETING

Our website uses Facebooks’ remarketing or "Custom Audience" function. With this option we can target individuals with personalised, interest-based advertising-ads. To do so Facebook uses cookies. These cookies are small files containing a numeric code in the browser of visitors to the website. Personal data of visitors to the website is not stored.

3.6.5 Twitter (“Tweet Button”)

3.6.5.1 We use Twitter Share button social plug-ins (provided by witter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter") to enable you to easily “Share” content found on our website, and thereby share this content on your Twitter account. No data is transmitted to Twitter by simply visiting our websites. Data is only transmitted when you have enabled the plug-in by clicking on the corresponding link. The plugins are marked with a Twitter logo for example in the form of a blue "Twitter bird." An overview of the Twitter plugins and their appearance can be found here: https://twitter.com/about/resources/buttons

3.6.5.2 When you visit a page of our website that contains such a social plugin, your browser makes a direct connection to the servers of Twitter. The content of the plugin is transferred from Twitter directly to your browser and integrated into the website. Because of this integration Twitter receives the information that your browser has accessed the relevant page of our website, even if you do not have a profile on Twitter or are just not logged into Twitter. This information (including your IP address) is transmitted from your browser directly to a server of Twitter in the US and stored there. If you are logged into Twitter, Twitter can connect your visit to our site to your Twitter account directly. If you interact with the plugins, for example by pressing the "Tweet" button, you agree that the corresponding information is also transmitted directly to a server of Twitter and stored there. The information will also be published on your Twitter account and may be presented to your contacts. For learning more about the purpose and the scope of data collection and further processing and use of your data by Twitter and your rights in this respect and settings options for protecting your privacy please refer to the privacy policies of Twitter: https://twitter.com/privacy. If you do not want that Twitter associates data collected on our website directly with your Twitter account, you need to log out of Twitter before your visit to our website. You can prevent loading of the Twitter plugins in your browser by using browser add ons, such as the script blocker "NoScript" ( http://noscript.net/).

3.6.6 Twitter Tailored Audience

Our website uses the "Tailored Audience" function. With this option we can appeal to visitors to the site with targeted advertisements. To do so Twitter uses so called tags. No personal data is stored in these tags.

4 Payment data

4.1 The following provisions of this section 4 do only apply to the use of the Platform and the App.

4.2 When purchasing nello one or subscribing to nello tello, you will have to submit payment information in order to allow processing of payments (depending on the payment method, e.g. a credit card number). Your payment will be processed via the third party payment provider Stripe, 185 Berry Street #550, San Francisco, CA 94107, US and Paypal, 2211 North First Street, San Jose, CA 95131, US.

4.3 When purchasing the nello one or nello tello, you will have to submit payment information in order to allow processing of payments (depending on the payment method, e.g. credit card number).

5 Email Marketing

5.1 Locumi provides information on special offers and discount promotions from time to time via email. Locumi do also offer an email newsletter service. In the marketing emails and in the newsletter, you will be provided with information on Locumi, Locumi’s products and current offers and surveys, provided that you have registered for it. You can unsubscribe from marketing emails and the newsletter at any time, either by de-registering from this service on the Platform, or by clicking on the unsubscribe link at the end of each marketing email or newsletter.

5.2 If you have given your consent to receiving marketing emails and the newsletter, you have issued the following declaration of consent:

I agree that my email address will be stored and used by Locumi, Zweibrückenstr. 2, 80331 München, Germany, for the purpose of email advertising directed to me (e.g. newsletters, information on special offers and discount promotions). This declaration of consent may be withdrawn at any time by sending an email to hello@nello.io. Additionally, a link to unsubscribe from future email advertisements is contained in each email sent. Further details on the use of personal data are set out in the nello.io/privacy.

6 Deletion of data, retention of data

6.1 You can completely delete your user account on the Platform. For this purpose, simply send an email with the subject “delete my profile” to hello@nello.io. Please note that use of the Platform and the App will no longer be possible once the user account has been deleted.

6.2 Locumi will retain your data to the extent necessary and allowed, this does apply especially for accounting data related to your purchases.

7 Use of usage data

7.1 Your personal data necessary for enabling you to use services offered by Locumi (“Usage Data”) will be used for handling the contractual relationship. Such Usage Data shall comprise your first name, last name, email address, address, location/gps data, service provider used, other users that have access to your location (first name, last name, email address and their location), every opening transaction with a time stamp and data as described in section 3.2.

7.2 Usage Data may be used by Locumi in anonymized form if need be, for the purposes of advertising, market research, improvement of services and for creating pseudonymous user profiles. You may object to the creation of pseudonymous user profiles. See section 8.2 for further details on how to object.

7.3 Your data may furthermore be used for the purposes described in the section 5, to the extent you have given your respective consent.

8 Information rights

8.1 You have the right to request that Locumi provides you with information on the data stored with regard to your person or your pseudonym.

8.2 Should you require further information or want to object to the use of your personal data, please contact support at the email address hello@nello.io.